fuel monitoring requirements and alternative monitoring petition

www.all4inc.comKimberton, PA | 610.933.5246Columbus, GA | 706.221.7688

Fuel Monitoring Requirements

Eric M Swisher| eswisher@all4inc.com | 610.933.5246 ext. 17March 14, 2013

Presented to AF&PA, AWC, & NCASI by All4 Inc.

2 Your environmental compliance is clearly our business.

Recordkeeping• Type and amount of fuel combusted on a monthly basis

Monthly Fuel Analysis• Each type of fuel combusted• Sampling programs separated by at least 14 calendar days

Quarterly Fuel Analysis• Each type of fuel combusted• 12 consecutive monthly fuel analyses are ≤ 75% of the

compliance level• Resume monthly fuel analysis for new fuels or if quarterly

fuel analysis is > 75% of the compliance level

Fuel Monitoring Requirements

www.all4inc.comKimberton, PA | 610.933.5246Columbus, GA | 706.221.7688

Alternative Monitoring Petition

Eric M Swisher| eswisher@all4inc.com | 610.933.5246 ext. 17March 14, 2013

Presented to AF&PA, AWC, & NCASI by All4 Inc.

4 Your environmental compliance is clearly our business.

Operating limits for specific control device not listed in Table 4

Establish an alternative operating limit with alternative monitoring parameter(s)

Alternative Monitoring Petition (AMP)

5 Your environmental compliance is clearly our business.

Process & Control Device Description• Diagrams

Four (4) elements of monitoring• Indicator(s) of performance• Measurement techniques• Monitoring frequency• Averaging time

Performance Evaluation Test Plan (if applicable) Quality Assurance Activities

AMP Elements

6 Your environmental compliance is clearly our business.

Alternative Monitoring Identification Alternative Monitoring Strategy

• Review U.S. EPA’s Applicability Determination Index (ADI)

Application Development Submittal to U.S. EPA

• At least 60 days prior to the Performance Test Approval or intention to deny from U.S. EPA

• Within 30 calendar days after AMP (and any additional information) has been received by U.S. EPA

Expect Several Iterations

AMP Process

www.all4inc.comKimberton, PA | 610.933.5246Columbus, GA | 706.221.7688

Questions ?

Eric M Swisher| eswisher@all4inc.com | 610.933.5246 ext. 17